News & Analysis as of

Customer-Loyalty Programs Opt-Outs

Sheppard Mullin Richter & Hampton LLP

The Comprehensive Privacy Law Deluge: Impact on Loyalty Programs

Among the various requirements under US state comprehensive privacy laws, those that relate to loyalty programs may be some of the most confusing. Only three states — California, Colorado and Florida — regulate these...more

McDermott Will & Emery

Colorado Attorney General’s Office Issues Draft Colorado Privacy Act Regulations

McDermott Will & Emery on

On September 30, 2022, the Colorado Attorney General’s Office (the AG’s Office) released draft regulations to the Colorado Privacy Act (the CPA). Before these proposed regulations take effect, however, there will be a lengthy...more

Foley & Lardner LLP

California Attorney General Announces First CCPA Enforcement Action

Foley & Lardner LLP on

On August 24, 2022, California Attorney General Rob Bonta announced a settlement with Sephora, Inc. that included a fine of $1.2 million for alleged violations of the California Consumer Privacy Act (CCPA). The settlement is...more

WilmerHale

CA AG Announces First Public CCPA Enforcement Decision

WilmerHale on

On August 24, 2022, California Attorney General Rob Bonta (“CA AG”) announced a $1.2 million settlement with Sephora, Inc. (“Sephora”), marking the first announced enforcement action under the California Consumer Privacy Act...more

Akin Gump Strauss Hauer & Feld LLP

Washington State Lawmakers Divided Over Private Right of Action and Other Relief in Dueling Data Privacy Bills

- The Washington state Senate has passed its version of a consumer data privacy bill as state lawmakers debate proposed legislation for the Washington Privacy Act, the state’s first data privacy law. - In their own bill,...more

Holland & Knight LLP

California Attorney General Releases Draft Regulations on the California Consumer Privacy Act: New Requirements Have Potentially...

Holland & Knight LLP on

The California Attorney General Xavier Becerra on Oct. 10, 2019, released the proposed text for the California Consumer Privacy Act Regulations (Regulations). The Regulations are intended to guide businesses on CCPA...more

BCLP

CCPA Privacy FAQs: If a business shares information through its loyalty program with a third party fulfillment company, is it...

BCLP on

Probably not. The CCPA broadly defines the term “sale” as including the act of “disclosing” or “making available” personal information “for monetary or other valuable consideration” from one business to another. The...more

BCLP

CCPA Privacy FAQs: Is a business required to post a “do not sell” link if it offers a loyalty program?

BCLP on

Not necessarily. California has two statutes that apply to the sale of information – The California Shine the Light Law and the California Consumer Protection Act. The California Shine the Light Law applies to companies...more

BCLP

CCPA Privacy FAQs: What rights does a consumer have in relation to a loyalty program?

BCLP on

Loyalty programs are structured in a variety of different ways. Some programs track dollars spent by consumers, others track products purchased. Some programs are free to participate in, others require consumers to purchase...more

Dorsey & Whitney LLP

Work in Progress - Potential CCPA Amendments Advance to Senate Appropriations Committee

Dorsey & Whitney LLP on

On July 9, 2019, the California Senate Judiciary Committee advanced a number of proposed amendments to the California Consumer Privacy Act (“CCPA” or the “Act”), including changes that would significantly impact the treatment...more

Holland & Knight LLP

California Consumer Privacy Act Update: Assembly Approves 12 Amendments - Changes Would Exclude Employees and Vehicle Information,...

Holland & Knight LLP on

• California's protracted legislative and regulatory process has complicated the landscape for businesses needing to implement the operational, technical and procedural changes required by the California Consumer Privacy Act....more

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